Netherlands: 2027 Tax Plan submitted to Parliament, includes full incorporation of Pillar Two side-by-side package
Package contains a range of other proposed tax measures.
September 16, 2026
The Dutch government has submitted the 2027 Tax Plan to the Lower House of Parliament. The package contains a range of proposed tax measures affecting businesses, individuals, housing corporations, employers, and investors.
- Corporate income tax: Proposed measures include changes to the participation exemption, business merger and demerger facilities, the innovation box regime, the education and research exemption, and the earnings stripping rule for housing corporations.
- Minimum tax: The Netherlands would fully incorporate the OECD side-by-side (SbS) package into the Minimum Tax Act 2024.
- Repeal of forestry exemption: The proposal includes repeal of the forestry exemption and an increase in the deduction percentage for the Energy Investment Deduction (EIA).
- Individual income tax: The measures address substantial interest rules, acquisition price determinations in certain cross-border situations, repeal of the deduction for specific medical expenses, and the phased repeal of various startup-related incentives.
- Wage taxes and social security contributions: Proposed changes affect employee discounts, stock option taxation for qualifying startups and scale-ups, travel allowances, company car taxation, pension rules, and the research and development (R&D) remittance reduction.
- VAT: The reduced VAT rate for floricultural products and ballooning would lapse as of 2028.
- Dividend withholding tax: A refund scheme would be introduced for Dutch investors in foreign investment institutions.
- Procedural law changes: The proposal includes temporary exceptions from certain information and electronic communication requirements for the Tax and Customs Administration and the Benefits Office.
- Real estate transfer tax: Measures include a reduction in the transfer tax rate for certain residential properties and a new exemption for specified transactions between housing corporations.
- Taxes and the environment: The package includes measures relating to fuel excise taxes, truck tolls, flight tax, the carbon border adjustment mechanism (CBAM), biofuel tax refunds, tap water taxation, waste disposal tax, and the industrial carbon dioxide (CO2) levy.
Read a two-page summary and September 2026 report (26 pages) prepared by the KPMG member firm in the Netherlands